In the case of Utah Division of State Lands v. United States et al., 1986, the Supreme Court ruled in favor of the federal government regarding ownership rights to land submerged under navigable waters. The state of Utah had argued that it was entitled to these lands based on its enabling act which granted it all unappropriated public lands within its borders upon admission into the Union in 1896. However, this claim was disputed by a group including Native American tribes and environmental organizations who asserted that these lands were reserved for tribal use before Utah's statehood. The court held that any title claims made by states must be explicitly stated at time of their admission into Union and since there was no such explicit transfer mentioned in Utah’s Enabling Act, they did not have automatic entitlement over those submerged lands.

In the dissenting opinion for Utah Division of State Lands v. United States, Justice Stevens argued that the majority's interpretation of the Submerged Lands Act was incorrect and inconsistent with its legislative history. He contended that Congress intended to grant states ownership over all lands beneath navigable waters within their boundaries, regardless of whether those lands were submerged at statehood or later became submerged due to natural changes in water levels. According to him, this broad interpretation is supported by both the language and purpose of the Act as well as previous court decisions interpreting it. Furthermore, he criticized the majority for relying on a flawed understanding of property law principles in reaching its decision. In his view, there was no legal basis for distinguishing between lands that were submerged at statehood and those that subsequently became submerged when determining state ownership under the Act.